The defendant is charged [in count
___] with bribe receiving by a labor official. The statute defining this
offense reads in pertinent part as follows:

a labor official is guilty of bribe
receiving by a labor official if (he/she) (solicits / accepts / agrees to
accept) any benefit from another person upon an agreement or understanding that
such benefit will influence (him/her) in respect to any of (his/her) acts,
decisions or duties as such labor official.

For you to find the defendant guilty
of this charge, the state must prove the following elements beyond a reasonable
doubt:

Element 1 - Labor officialThe first element is that the
defendant was a labor official within the meaning of that term, on the dates
alleged. "Labor
official" means any duly appointed or elected representative of a labor
organization or any duly appointed or elected trustee or representative of an
employee welfare trust fund.

Element 2 - Benefit soughtThe second element is that the
defendant (solicited / accepted / agreed to accept) a benefit of <insert
benefit> from <insert alleged provider of bribe>. "Benefit"
means monetary advantage or anything regarded by the beneficiary as monetary
advantage, including a benefit to any person or entity in whose welfare the
beneficiary is interested.

Element 3 - Intent to influenceThe third element is that the
defendant (solicited / accepted / agreed to accept) that benefit upon the
understanding that such benefit would influence (him/her) in respect to any of
(his/her) acts, decisions or duties as a labor official.

You must find that the state has
proved beyond a reasonable doubt that the defendant (solicited / accepted /
agreed to accept) the benefit with the specific intent that the receipt of the
benefit would influence (his/her) acts, decisions or duties. A person acts "intentionally"
with respect to a result when (his/her) conscious objective is to cause such
result. <See
Intent: Specific, Instruction 2.3-1.>

Conclusion

In summary, the state must prove
beyond a reasonable doubt that 1) the defendant was a labor official on the
dates alleged, 2) the defendant (solicited / accepted / agreed to accept) a
benefit of <insert benefit> from <insert alleged provider of bribe>,
and 3) the defendant (solicited / accepted / agreed to accept) that benefit upon
the understanding that such benefit would influence (him/her) in respect to any
of (his/her) acts, decisions or duties as a labor official.

If you unanimously find that the state has proved beyond a
reasonable doubt each of the elements of the crime of bribe receiving by a labor
official, then you shall find the defendant guilty. On the other hand, if you
unanimously find that the state has failed to prove beyond a reasonable doubt
any of the elements, you shall then find the defendant not guilty.